05/24/2010
We have several loan production offices. They don't have cash drawers, are not listed as branches, and they don't service the deposit customer walking in off the street. Do we need signage such as the FDIC stickers? What if a courier for the bank picks up some proof work where only our employees make deposits instead of running to a branch?
04/19/2010
Where can we find information about paying/returning debit card transactions? Would we have to find out from MasterCard? Management wants something in writing about why we have to pay those when a customer is already in the negative. They are worrying that we could pay something over our legal lending limit and then get in hot water with our regulators.
09/14/2009
Our Lending Department has created a “fact sheet” to be given to realtors. The understanding is that these fact sheets would not be provided to consumers. Do you think I could consider these as not being an advertisement, and therefore not having to worry about trigger terms?
07/13/2009
Regarding Reg CC Compliance and differentiating between banking and business days: I thought a banking day was a day when a branch may offer hours and basic services(i.e., a Saturday), but not all services are available to a customer, whereas a business day is Mon-Fri (excluding holidays) when all services are available. Now I am reading in a tutorial that a banking day must be a business day, so Saturday should never be considered a banking day. What is your answer?
05/04/2009
When renewing a note loan, is it necessary to collect the interest due at maturity or can it be added back to the principal balance of the loan?
02/23/2009
What loan to deposit ratio would the regulators like to see with regards to CRA?
02/16/2009
Is there regulatory guidance on the amount or percent of exception loans (i.e. LTV, D/I, credit score...) that can be made relative to your portfolio?
11/24/2008
Our regulators have requested that our bank more clearly define and document its credit policies. What should be included?
06/16/2008
Now that the NFIP changed the flood insurance coverage to take into account the replacement cost value (RCV) where the appraised value was previously used, how will this affect commercial buildings? This change appears to make more sense for single family dwellings due to the equation (lesser of the debt, value or max coverage available). How will the examiners verify the RCV on a commercial property?
06/09/2008
We are aware of the requirement for a full Title XI appraisal for loans over $250K and secured by real estate. However, if there are multiple properties involved, the value of each being less than 100K, can evaluations be used instead?